Producer responsibility for electronics
Electrical and electronic equipment is the source of the fastest growing waste stream in Europe. Electrical products consist of a mixture of hazardous and valuable materials. Based on circular thinking regulations have been introduced all over the EU giving producers and importers responsibility for their products from design and production to collection and environmental treatment of end-of-life products.
In the EU, policies regarding producer responsibility and resources have been adopted relating to products dependent on electric currents, batteries, and vehicles. In each Member State a register has been established where you must be registered in order to legally place in-scope products on the market. In Denmark the producer register is found in DPA. On these pages we have gathered information for those of you that need to find out whether or not you need to register your business.
Note! The rules on producer responsibility are the same whether you are a producer or an importer.
Which products are covered?
Electrical and electronic equipment is defined as:
- Equipment which is dependent on electric currents or electromagnetic fields.
- Equipment for the generation, transfer and measurement of electric currents or electromagnetic fields.
Some types of equipment are subject to exemptions.
The following information is meant to help identify whether equipment is covered, which category it falls under, and how to mark equipment according to the rules.
Electrical and electronic equipment is defined as:
‘Dependent on electric currents’ means that this equipment cannot fulfil its purpose if the current or field is disconnected.
This may be, for instance, a petrol-driven generator driving electrical hand tools on a construction site, a wind turbine, a fuel cell, or a solar panel.
In the transmission of electric currents or electromagnetic fields, cables, antennas, switches, etc. are used. Therefore, this type of equipment is covered just like any other electrical and electronic equipment.
Voltmeters, radars, and magnetic field meters. Whether equipment is active or passive plays NO role. Active means equipment using currents to work properly, while passive equipment receives or registers electric currents or electromagnetic impulses. An active product is, for instance, an antenna with integrated amplifier, where the passive equivalent would be the antenna without this amplifier.
Components or semi-products are parts integrated in the production of electrical equipment or used as spare parts in the repair of electrical equipment. Components are generally not subject to producer responsibility.
A PC consists of a number of components such as power supply, graphics card, motherboard, sound card, hard disk, RAM, CPU, etc. incorporated in a case. When the different parts are sold in large volumes (bulk) to a company that exclusively uses the parts to assemble and sell finished computers the different parts are considered as components. The finished PC is then covered by the rules on producer responsibility.
If, however, the parts are sold separately to an end user (retail packs) they are all considered as finished products and thereby covered by the rules on producer responsibility. If the parts are sold in disassembled form the assembly kit is considered as a finished product, thereby covered by the rules on producer responsibility.
Other equipment that is typically used together with the PC, such as screen, keyboard, mouse, external hard disk, or external CD drive are also considered as finished products in their own right and are covered by producer responsibility. This also applies to drivers for loudspeakers.
Read more about scoping of equipment covered by legislation (WEEE)
Is your business subject to producer responsibility?
We can help you find out whether your business and the products you sell are subject to producer responsibility.Check to see if you are covered
In order to monitor product and waste streams the electrical products you sell must be categorised and reported in one or more of the seven product categories listed in the WEEE Order.
Such equipment must be reported by category and broken down on equipment for professional use or products generally used in private households.
This division into categories is based on the treatment logistics used in the management of end-of-life products.
Temperature exchange equipment is electrical and electronic equipment (EEE) with internal circuits where substances other than water – e.g. gas, oil, refrigerants, or a secondary fluid – are used for the purpose of cooling and/or heating and/or dehumidifying.
This may be refrigerators, freezers, equipment automatically delivering cold products, air-conditioning equipment, dehumidifying equipment, heat pumps, radiators containing oil and other temperature exchange equipment using fluids other than water for the temperature exchange.
Screens and monitors are EEE intended to provide images and information on an electronic display – regardless of its dimensions – such as cathode ray tubes (CTR), liquid-crystal displays (LCD), light-emitting diode (LED) displays, and other types of electronic displays. In addition, the directive mentions under category 2 other equipment containing screens having a surface greater than 100 cm2. Not all equipment having a surface greater than 100 cm2 falls under category 2. Only EEE where the screen’s surface is greater than 100 cm2 and where the main purpose is to display images and information on the screen belongs to category 2.
Equipment such as laptops, notebooks, tablets, e-readers with a screen surface greater than 100 cm2 belongs to category 2, while this is not the case for washing machines, refrigerators, printers, mobile phones (smartphones, phablets etc.) even if their screen surface is greater than 100 cm2, as their main purpose is not to display information on a screen.
Light sources irrespective of size is “equipment for the generation of light” – in other words electrical light sources (including LED light sources, but not LED luminaires) that are solely intended for fitting in other equipment.
At least one external dimension more than 50 cm. EEE that is not under category 1, 2, or 3.
Any external dimension more than 50 cm. The external dimensions of the equipment must be measured in a state where equipment is ready to use. For correct measurement of the equipment, see under 3 (“EEE measurement method”)
No external dimension more than 50 cm, EEE that is not under category 1, 2, 3, 4, or 6.
The measurement of dimensions follows the same definition as given above under category 4. Following this, if the largest external dimension is 50 cm or less and it is not IT and telecommunication equipment, it complies with the definition of category 5.
EEE that is not under category 1, 2, 3, 4, or 5. IT equipment is equipment that can be used for collecting, transmitting, processing, storing, and showing information.
Telecommunication equipment is equipment designed to transmit signals – voice, video, and data – electronically over a certain distance. The measurement of dimensions follows the same definition as given above under category 5. So, if the equipment is IT and telecommunication equipment it complies with the definition of category 6.
Photovoltaic panels are intended to be used in a system that is designed, assembled, and installed by professionals for permanent use at a defined location to produce energy from solar light for public, commercial, industrial, and residential applications.
Who is the end-user?
The end-user is: the private person, the business, or the private or public institution that uses the piece of equipment when it becomes waste.
It is important to identify whether the end-user of a product is a business or a private household. This distinction is related to the nature of the product, the logistics in waste management, and the take-back duties under the producer responsibility scheme.
Equipment defined as ’end-user households’ is produced for use in private households and normally ends its life in the waste stream collected by the local authority, for instance through recycling centres and the so-called collection in the vicinity of end-users, e.g. through bulky waste services.
The local authority ensures the separation of waste electronics into six waste fractions. Subsequently, it is the duty of your business to collect these waste electronics from the local authority and ensure further environmental treatment.
If the local authority finds that a batch is a larger (uniform) waste quantity than would normally be seen in an ordinary household the local authority can reject reception. In these cases, waste can be taken to the regional collection sites of the compliance schemes.
Equipment defined as for professional use is produced specifically for professional use in commercial businesses. Here, your business is basically responsible for collection and subsequent environmental treatment of the end-of-life equipment. Thereby, the end-user has the right to take back end-of-life equipment to the producer. Alternatively, the producer can agree with the purchaser that the latter ensures environmentally correct management of this waste – this is called “transfer of responsibility”.
Further information about end-user
Electrical and electronic equipment that may be used in private households, including equipment of the same type and volume as used in private and public institutions and businesses. At the end of its useful life such equipment will typically end up at a municipal recycling centre.
Electrical and electronic equipment specifically manufactured for use in private and public institutions and businesses and being electrical and electronic equipment that is not for use in private households. The user is responsible for the management of his/her end-of-life equipment and takes it either back to the producer or directly to an environmentally approved recycling facility.
Electrical equipment containing batteries
Producer responsibility and associated duty of registration apply separately for electrical equipment and batteries.
In cases where electrical equipment contains batteries or accumulators, electrical equipment and batteries/accumulators are registered separately.
It is a general requirement for equipment containing batteries that the battery or the accumulator must be removable from the equipment. The purpose of this separation is that it must be possible to manage and recycle electrical equipment and batteries separately.
Are you subject to producer responsibility? Here are your duties…
If you are subject to producer responsibility, there are a number of tasks and requirements you should attend to.
The most important duties are:
MarkingRead more about Marking of electronics
You must mark your equipment with a crossed-out wheeled bin.
RegistrationRead more about Registration
You must register in the national register with DPA. You may not sell electronics or batteries without having an approved registration.
ReportingRead more about Reporting
You must report annual quantity of products sold on the Danish market. In addition, you must report the quantity of end-of-life products you have taken back, and environmentally treated end-of-life equipment.
Take-back from private householdsRead more about take-back of equipment for private use
You must take back or contract collection of waste equipment and secure approved environmental treatment in view of recovering the material resources contained in the waste.
The above can be assumed by the producer (individual complier) or the producer can enter an agreement with a compliance scheme. In certain conditions a business not established in Denmark can designate an authorised representative with a Danish CVR number to assume the legal responsibility for products sold directly to Danish end-users, such as sales on the Internet.
Which businesses must register?
Producers and importers of electrical products in Denmark, or the first level of the distribution chain, must register in the national producer register with DPA in order to legally sell this type of products on the Danish market. Without such registration it is illegal for dealers to buy your products.
There is free access to search out all approved businesses in the public part of the register through the SEARCH function on our website
Producer responsibility covers the following businesses
- producing electrical equipment or having such equipment produced and selling this equipment in their own name/brand on the Danish market.
- importing electrical equipment from the EU or from outside the EU and selling this equipment on the Danish market.
- distance selling electrical equipment from an EU member state (incl. EFTA and EEA countries except for Switzerland) directly to end-users in Denmark. Such businesses must register with an authorised representative in Denmark.
- distance selling electrical equipment from outside the EU (incl. Switzerland) directly to end-users in Denmark.
What to do?
The above can be assumed by the producer (individual complier) or the producer can enter an agreement with a compliance scheme. In certain conditions a business not established in Denmark can designate an authorised representative to assume the responsibility on its behalf.
Guidelines for Registration and Annual Reporting
Step-by-step document : Guidelines for registration and reporting 2022.
See how to register as a new producer in the producer register
See registered producers
See registered producers and importers of electronics, batteries, and vehicles
See information about collective vs individual compliance schemes and authorised representatives
See which other players in addition to producers, importers, and authorities are involved in the producer responsibility with various roles
Read more about annual reporting of electronics
Economy and fees
See current fees for products subject to producer responsibility
Legislation relating to electronics
See the statutory basis for producer responsibility for electronics
See which types of electrical equipment are subject to exemptions
Marking of equipment
Read more about requirements for marking of electronics
Management of waste electronics and batteries
Read more about how to collect and manage waste electronics and end-of-life batteries
tonnes placed on the market in 2021
tonnes of electronics collected in 2021
tonnes of electronics recycled in 2021